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Labo Jr. vs. COMELEC and Lardizabal

Ramon Labo was elected mayor of Baguio City but his citizenship was questioned because he had previously renounced his Philippine citizenship by becoming naturalized in Australia. The Supreme Court ruled that Labo was not a citizen of the Philippines at the time of his election and was therefore ineligible to serve as mayor. Philippine citizenship cannot be easily regained after renunciation and requires a formal act of rededication to the Philippines and affirmation of loyalty. The court ordered Labo to vacate his office as mayor.

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92 views2 pages

Labo Jr. vs. COMELEC and Lardizabal

Ramon Labo was elected mayor of Baguio City but his citizenship was questioned because he had previously renounced his Philippine citizenship by becoming naturalized in Australia. The Supreme Court ruled that Labo was not a citizen of the Philippines at the time of his election and was therefore ineligible to serve as mayor. Philippine citizenship cannot be easily regained after renunciation and requires a formal act of rededication to the Philippines and affirmation of loyalty. The court ordered Labo to vacate his office as mayor.

Uploaded by

Robinson Mojica
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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UNIVERSITY OF SANTO TOMAS

FACULTY OF CIVIL LAW


CFL – Atty. Ismael Sarangaya

Ramon L. Labo Jr. vs. The Commission on Elections (COMELEC) En Banc and Luis L. Lardizabal
G.R. No. 86564, 1 August 1989
Philippine citizenship is not a cheap commodity that can be easily recovered after its renunciation. It may be restored
only after the returning renegade makes a formal act of re-dedication to the country he has abjured and he solemnly
affirms once again his total and exclusive loyalty to the Republic of the Philippines. This may not be accomplished
by election to public office.
FACTS:
Petitioner Ramon Labo was elected as the Mayor of Baguio City but his citizenship was being questioned.
Petitioner married an Australian citizen, obtained an Australian passport, and registered as an alien with the CID
upon his return to the Philippines in 1980. The Australian Government dated 12 August 1984, through its Consul
in the Philippines, stated that the petitioner was still an Australian by reason of his naturalization in 1976.
The petitioner now claims that his naturalization in Australia made him at worst only a dual national and did not
divest him of his Philippine citizenship. Such a specious argument cannot stand against the clear provisions of
CA No. 63, which enumerates the modes by which Philippine citizenship may be lost. Among these are: (1)
naturalization in a foreign country; (2) express renunciation of citizenship; and (3) subscribing to an oath of
allegiance to support the Constitution or laws of a foreign country, all of which are applicable to the petitioner.
ISSUE:
Whether or not Ramon Labo was a citizen of the Philippines at the time of his election on 18 January 1988, as
mayor of Baguio City.
RULING:
NO. Under CA No. 63 as amended by PD No. 725, Philippine citizenship may be reacquired by direct act of
Congress, by naturalization, or by repatriation. It does not appear in the record, nor does the petitioner claim,
that he has reacquired Philippine citizenship by any of these methods. He does not point to any judicial decree of
naturalization as to any statute directly conferring Philippine citizenship upon him. Neither has he shown that
he has complied with PD No. 725, providing that: natural-born Filipinos who have lost their Philippine citizenship
may reacquire Philippine citizenship through repatriation by applying with the Special Committee on
Naturalization created by Letter of Instruction No. 270, and, if their applications are approved, taking the
necessary oath of allegiance to the Republic of the Philippines, after which they shall be deemed to have
reacquired Philippine citizenship. The Commission on Immigration and Deportation shall thereupon cancel their
certificate of registration.
The petitioner is not now, nor was he on the day of the local elections on 18 January 1988, a citizen of the
Philippines. In fact, he was not even a qualified voter under the Constitution itself because of his alienage. He was
therefore ineligible as a candidate for mayor of Baguio City, under Section 42 of the Local Government Code
providing in material part as follows:
Sec. 42. Qualifications. — An elective local official must be a citizen of the Philippines, at least twenty-three
years of age on election day, a qualified voter registered as such in the barangay, municipality, city or
province where he proposes to be elected, a resident therein for at least one year at the time of the filing of
his certificate of candidacy, and able to read and write English, Filipino, or any other local language or
dialect.
The petitioner argues that his alleged lack of citizenship is a “futile technicality” that should not frustrate the will
of the electorate of Baguio City, who elected him by a ”resonant and thunderous majority.” To be accurate, it was
not as loud as all that, for his lead over the second-placer was only about 2,100 votes. In any event, the people of
that locality could not have, even unanimously, changed the requirements of the Local Government Code and the
Constitution. The electorate had no power to permit a foreigner owing his total allegiance to the Queen of
Australia, or at least a stateless individual owing no allegiance to the Republic of the Philippines, to preside over
them as mayor of their city. Only citizens of the Philippines have that privilege over their countrymen.
It remains to stress that the citizen of the Philippines must take pride in his status as such and cherish this
priceless gift that, out of more than a hundred other nationalities, God has seen fit to grant him. Having been so
endowed, he must not lightly yield this precious advantage, rejecting it for another land that may offer him
material and other attractions that he may not find in his own country. To be sure, he has the right to renounce
the Philippines if he sees fit and transfer his allegiance to a state with more allurements for him. But having done
so, he cannot expect to be welcomed back with open arms once his taste for his adopted country turns sour or he
is himself disowned by it as an undesirable alien.
Philippine citizenship is not a cheap commodity that can be easily recovered after its renunciation. It may be
restored only after the returning renegade makes a formal act of re-dedication to the country he has abjured and
he solemnly affirms once again his total and exclusive loyalty to the Republic of the Philippines. This may not be
accomplished by election to public office.
DISPOSITION:
WHEREFORE, petitioner Ramon J. Labo, Jr. is hereby declared NOT a citizen of the Philippines and therefore
DISQUALIFIED from continuing to serve as Mayor of Baguio City. He is ordered to VACATE his office and
surrender the same to the Vice-Mayor of Baguio City, once this decision becomes final and executory. The
temporary restraining order dated January 31, 1989, is LIFTED.

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